OneLBriefs

NLRB v. Jones & Laughlin Steel Corp.

SCOTUS - 1937

Facts:

The steel corporation (D) fired some of its employees after they attempted to unionize.

The NLRB sued D under violations of the National Labor Relations Act.

D argued that the NLRA (Wagner Act) was unconstitutional as too expansive use of Congress's commerce power.

Procedural History:

Lower courts held act unconstitutional.

SCOTUS reversed, act constitutional.

Issues:

Can Congress use Commerce Clause power to regulate labor relations?

Holding/Rule:

Congress can use the Commerce Clause power to regulate labor relations since labor relations have a direct effect on interstate commerce and the act can be construed narrowly to only restrict activities that would stifle interstate commerce.

Reasoning:

The commerce contemplated by the act is interstate in the constitutional sense.

Acts which directly burden or obstruct interstate commerce, or its free flow, are within the reach of the congressional power.

The congressional authority to protect interstate commerce from burdens and obstructions is not limited to transactions which can be deemed to be an essential part of a flow of interstate commerce.

Although activities may be intrastate in character when separately considered, if they have such a close and substantial relation to interstate commerce that their control is essential or appropriate to protect that commerce from burdens or obstructions, Congress cannot be denied the power to exercise that control.

Stoppage in operations due to industrial strife would have a most serious effect upon interstate commerce; they would not be indirect or remote, especially considering D's widespread operations.

Dissent:

WTF, this is breaking with precedent.

Almost all corporations take raw materials from outside their state, fabricate within the state, and then ship beyond the state; the majority allows Congress to regulate almost every field of industry.